planning report PDU/2824/01 21 September 2011 Land Adjoining Bastable Avenue, Renwick Road in the London Borough of Barking & planning application no.11/00727/FUL

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

The proposal Redevelopment of site to provide 276 affordable residential units involving a mix of houses and flats in buildings of three and four storeys together with 249 on-street and courtyard car parking spaces, related highways works, and revisions to the bus stand/turning area and the formation of a new public square. The applicant The applicants are Thames Partnerships for Learning Ltd & London Borough of Barking & Dagenham and the architect is Pollard Thomas Edwards Architects.

Strategic issues Principle of land use, housing mix, quality of housing including space standards, affordable housing/rent, tenure split, children’s play space, density, urban design & landscaping, inclusive design, sustainable development, flood risk management, employment & training, transport & parking are the key strategic issues relevant to the proposed development.

Recommendation

That Barking & Dagenham Council be advised that the application does not comply with the London Plan, for the reasons set out in paragraph 90 of this report; but that the possible remedies set out in paragraph 92 of this report could address these deficiencies.

Context

1 On 22 August 2011, the Mayor of London received documents from Barking & Dagenham 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 2 October 2011 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 information for the Mayor’s use in deciding what decision to make.

page 1 2 The application is referable under Category 1A of the Schedule to the Order 2008: ”Development which compromises or includes the provision of more than 150 houses, flats, or houses and flats.”

3 Once Barking & Dagenham 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; take it over for his own determination; or allow the Council to determine it itself.

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 4.2ha application site as shown below is rectangular in shape and is bisected by Bastable Avenue, with the larger part of the site lying to the north of Bastable Avenue. It forms the Eastern end of the Thamesview Estate, Barking, which lies between the A13 and the . The Thames View Estate is a primarily residential housing estate developed by the London Borough of Barking in the 1950s and 1960s. It is located within the western part of the borough and lies approximately 2.7km south west of Barking town centre.

The application site – Source: applicant’s planning application doc.

6 The site is bordered to the north by a surface water course, known locally as the Ship and Shovel Drain or the Mayes Brook (Eastern Branch), which, together with adjoining land to the north and east is designated as a Site of Importance for Nature Conservation (SINC). The area to the south comprises former ash pits green space that is identified in the Core Strategy as a key regeneration area and SINC. To the east is Renwick Road, which is tree lined with raised land along its eastern side, with four storey residential blocks and two-three storey houses beyond. Renwick Road rises on an embankment towards the north where the road crosses the railway line on a bridge. To the west is Crouch Avenue, a local road with on-street parking that is accessed via Chelmer Crescent and currently closed at its southern end.

7 Crouch Avenue is fronted by two storey terraced houses with front gardens, many converted to parking use, and three storey maisonette blocks. Beyond Crouch Avenue lies the

page 2 remaining area of the Thames View Estate. Bastable Avenue, the main distributor road for Thames View Estate crosses the site running east-west and is controlled by a peak-hour, bus-only gate at the junction with Renwick Road. A bus stand and turning circle developed and managed by TfL is located within the site to the north of Bastable Avenue and adjacent to the junction with Renwick Avenue.

8 The site is now vacant, following the demolition of all buildings in 2008, with the exception of three sub-stations, trees and roads. A sub-station is located towards the centre of the site adjacent to the existing vehicular access point from Crouch Avenue, another north west of the site located off Wivenhoe Road and another south of the junction between Bastable Avenue and Renwick Road.

9 The nearest section of the Transport for London Road Network is the A13 Ripple Road, located approximately 650 metres from the site entrance. Three bus routes (EL1, EL2 and 387) are located within 400 metres of the site, with the nearest bus stops located on Bastable Avenue. There are no rail services located within an acceptable walking distance, and as such, it has been demonstrated that the site records a poor public transport accessibility level of 2, on a scale of 1-6, where 6 is classed as excellent.

Details of the proposal

10 Redevelopment of site to provide 276 affordable residential units involving a mix of houses and flats and maisonettes in buildings of three and four storeys comprising 70 one-bedroom units, 35 two-bedroom units, 124 three-bedroom units (of which 104 are houses) and 47 four-bedroom houses.

11 The scheme incorporates 249 on-street and courtyard car parking spaces, related highways works, including the creation of a new southern extension to Crouch Avenue and a new junction with Bastable Avenue, landscape and play areas, ancillary services and utilities, revisions to the bus stand/turning area and the formation of a new public square. Case history

12 A pre - planning application meeting took place at City Hall between the GLA‘s planning officers and the applicants and their consultants on 28 July 2011 and the proposed development was broadly supported. Strategic planning issues and relevant policies and guidance

13 The relevant issues and corresponding policies are as follows:

 Housing London Plan; PPS3; Housing SPG; Providing for Children and Young People’s Play and Informal Recreation SPG, Housing Strategy; Interim Housing SPG; Housing SPG EiP draft  Affordable housing London Plan; PPS3; Housing SPG, Housing Strategy; Interim Housing SPG; Housing SPG EiP draft  Density London Plan; PPS3; Housing SPG; Interim Housing SPG; Housing SPG EiP draft  Urban design London Plan; PPS1  Access London Plan; PPS1; Accessible London: achieving an inclusive environment SPG; Planning and Access for Disabled People: a good practice guide (ODPM)

page 3  Sustainable development London Plan; PPS1, PPS1 supplement; PPS3; PPG13; PPS22; draft PPS Planning for a Low Carbon Future in a Changing Climate; the Mayor’s Energy Strategy; Mayor’s draft Climate Change Mitigation and Adaptation Strategies; Mayor’s draft Water Strategy; Sustainable Design and Construction SPG  Flooding London Plan; Mayor’s draft Water Strategy; PPS25, RPG3B  Employment London Plan; PPS4; Industrial Capacity SPG  Transport London Plan; the Mayor’s Transport Strategy; PPG13; Land for Transport Functions SPG

14 For the purposes of Section 38(6) of the Planning and Compulsory Purchase Act 2004, the development plans in force for the area are the Barking & Dagenham 2010 Core Strategy, the 2010 Site specific Allocations DPD, the 2011 Borough Wide Development Policies DPD and the 2011 London Plan and the emerging London Riverside OAPF.

Principle of use

15 The Thames View Estate is allocated as ‘SSA SM13: Thames View Regeneration Site‘, a site for housing redevelopment within the LBBD’s ‘Site Specific Allocations Development Plan Document’ which was adopted in December 2010. The Council owns the land and is planning on bringing the site forward for redevelopment through the Local Housing Company.

16 A Masterplan completed in 2009, forms the basis of development coming forward on this site. The Site Specific Allocations DPD sets out detailed proposed uses and design requirements for the site.

17 Whilst the proposed housing scheme on the site is supported in principle, the applicant should consider the compatibility of the scheme with the emerging London Riverside OAPF design aspirations.

Estate renewal

18 The London Plan 2011 and London Housing Strategy support neighbourhood renewal and regeneration. However, historically this process has often been associated with a reduction in housing capacity. In some circumstances, the loss of affordable housing has been exacerbated by estate renewal being associated with moves to introduce a wider tenure/social mix. While in itself this supports the strategic objective to achieve mixed and balanced communities, the reduction in affordable housing provision (especially social rented provision) sometimes associated with these initiatives has undermined the Mayor’s overall objective to increase affordable housing.

19 Policy 3.14 ‘Existing Housing‘ of the London Plan 2011 resists the loss of housing, including affordable housing, without its planned replacement at existing or higher densities. This policy also states that, at least, equivalent floor space should be provided in housing redevelopments. Paragraph 3.82 in support of Policy 3.14 gives further advice on the Mayor’s approach to estate renewal. Further detailed guidance is set out in Section 20 of the Housing SPG. This clarifies that there should be no net loss of affordable housing, which may be calculated on a habitable room basis, and should exclude right to buy properties. Replacement affordable housing can be of a different tenure mix, where this achieves a better mix of provision.

20 The planning statement states that the number of units that was demolished in 2008 was 247. This compared to the current proposal of 276, there is a small increase (29 units) over the number previously on site. Therefore, there is no net loss of affordable housing in terms of units or

page 4 floor space. However, it should be noted that the current provision of affordable housing is affordable rent rather than social rent. This should be assessed in detail and is dealt with below.

Affordable housing

21 At the pre-application stage it was highlighted that the applicant needed to provide details of the approach toward affordable housing and the market rent proportions to be included in the application in order to support the delivery of social and affordable family housing and provide the rationale for reduced density from the earlier masterplan.

22 As stated above the re-provision is 100% affordable rent.

23 Policy 3.10 ‘definition of affordable housing‘ of the London Plan 2011 in paragraph 3.63 notes that “Government has recently introduced a new Affordable Rent housing product which “is to be allocated to the same people who are currently eligible for social rent, but that the level of rent will be set in a different way. It is important to note that social rented dwellings can still be provided but only in exceptional cases will they attract funding from the Homes and Community Agency... [boroughs] will wish to work closely with Registered Providers and developers in ensuring that they can obtain the right mix of affordable housing to best suit the needs of their area”. Government proposes to define Affordable Rent as “rented housing provided by registered providers of social housing, that has the same characteristics as social rented housing except that it is outside the national rent regime, but is subject to other rent controls that require it to be offered to eligible households at a rent of up to 80% of local market rents”.

24 Government has also provided further guidance on bringing this product forward to meet relevant housing needs. As an interim measure the Mayor intends to provide guidance in the Housing SPG on how this new product can be used to implement the policies of this Plan (including Policy 3.11). He also intends to bring forward an early alteration to the Plan’s policies on affordable housing to incorporate the new product and address the implications of the new policy direction.

25 It should be noted that affordable rent, although not operated under the same agreements as social rented housing, is considered an affordable housing product, and is intended to be available to those eligible for social rented housing. It is also solely a rented product, as opposed to intermediate housing, which typically involves an element of sale to the occupier. In the recent funding programme issued by the Homes and Communities Agency for the period 2011 to 2015, it has been made clear that funding for social rented products will only be supported in limited circumstances.

26 It is acknowledged that the target within London Plan 2011 Policy 3.12 ‘Negotiating affordable housing on individual private residential and mixed use schemes‘ is not a site specific target, and that the recent shifts in government policy are not currently reflected in strategic policy. The introduction of a new affordable housing product, together with the lack of government funding for social rented housing, will impact on the ability of developments to meet the strategic target within Policy 3.12.

27 The scheme proposes the provision of 276 new residential units comprising 100% within the affordable rent model contained within a wide range of unit sizes. Of the total units proposed, 49 units (17.8%) are to be provided at (50% of market rent), and 82 units (29.7%) at 65% of market rent and 145 units (52.5%) at 80% of market rent.

28 GLA officers note that the proposal would not include any traditional social rented units. It is, however, understood that rent discounts at 50% may result in affordable rent units which would

page 5 be affordable to a greater proportion of those on the Council’s housing waiting list, and in this regard, may be comparable to traditional social rented units.

29 London Plan 2011 Policy 3.9 promotes mixed and balanced communities, and seeks a more balanced mix of tenures in all parts of London, particularly in some neighbourhoods where social renting predominates. While the proposals are for 100% affordable provision, based on the affordable rent model, a varying level of discounted has been proposed (50%-80% of the local market rate). It is likely that the affordable rent units that are targeted at 50% market rent will in fact be affordable to those tenants who would have previously been allocated social rented housing, while the 80% market rent units will respond to a slightly different housing need. Officers acknowledge that the intention to use varying rates of discount would allow the affordable rent products to be allocated to different socio-economic groups, which in turn would help to promote a mixed community. This approach is supported in principle.

Housing mix / unit sizes

30 Mix of units: London Plan 2011 Policy 3.8 encourages a full range of housing choice. This is supported by the London Plan Housing SPG, which seeks to secure family accommodation within residential schemes, particularly within the social rented sector, and sets strategic guidance for councils in assessing their local needs. Policy 3.11 of the London Plan 2011 states that within affordable housing provision, priority should be accorded to family housing. Recent guidance is also set out in the London Plan Interim Housing SPG (April 2010). Also relevant is Policy 1.1, part C, of the London Housing Strategy, which sets a target for 42% of social rented homes to have three or more bedrooms.

Dwelling comparison with the Mayor’s Housing SPG - (Source: applicant’s doc)

31 The proportion of family units provided at 50% market rented that could be considered as traditional social rented is over 70%, significantly exceeding the target set out in the London Plan and the Mayor’s Housing SPG. In addition, significant amounts of family housing consisting of three and four bedroom houses are evenly distributed across the site. This is welcomed and supported.

32 Unit sizes / space standards - The unit sizes for the proposed residential units (as shown in the Table) meet the space standards of the London Housing Design Guide and some of them (in particular the three or more bedrooms) are over the target, which is welcomed.

page 6 Dwellings Area

1 bedroom, 2 person flats 50sqm and 55sqm

2 bedrooms, 4 person flats/duplex 72.5sqm and 94.5sqm

2 bedrooms, 4 person wheelchair accessible duplex 110sqm

3 bedrooms, 5 person wheelchair accessible duplex 112sqm

3 bedrooms, 5 person house 108.5sqm

4 bedrooms, 6 person house 115.6sqm

Density

33 London Plan 2011 Policy 3.4 seeks to optimise the housing potential of sites, having regard to local context, design principles and public transport accessibility. The Mayor’s Housing SPG acknowledges that significantly increased density may be necessary to generate sufficient value from market development to support the replacement of affordable housing.

34 Once the ELT route is fully functional the site has a public transport accessibility level of two and the site is just over 4Ha. The proposed density for the scheme is 68 units/ha and 291 hr/ha, and the London Plan indicates that an appropriate density for this site is between 50-95 units/ha and 150-250 hr/ha. The proposed density sits comfortably within the London Plan density matrix (Table 3.2) in terms of units per hectare but it is slightly greater in terms of habitable rooms per hectare. As this slight increase is due to the provision of high percentage of family housing, the proposed density is considered acceptable.

Children’s play space

35 Some discussion was held at the pre-application meeting regarding the provision of play and amenity space and officers welcomed the fact that the applicant has given consideration to a play strategy, and provision of doorstep play for under fives, local playable space for five to eleven year olds, and neighbourhood play for (teenagers) those twelve and over at various locations within the development.

36 In developing the proposal further, the applicant had regard to London Plan 2011 Policy 3.6, and the methodology within the Mayor’s supplementary planning guidance ‘Providing for Children and Young People’s Play and Informal Recreation’ and the play strategy included an assessment of the location and condition of any existing facilities in the surrounding area.

37 The planning statement highlighted that Newlands Park (1.57ha) is the largest neighbourhood park located approx 500m to the west of the site. It includes planning and landscaping, picnic space, a toddler play area, skating, basketball and a teen’s area. A fenced basket ball court and skateboard area are located to the rear of the community centre at the junction of Bastable Avenue and Farr Road approx 300m west of the site.

38 The applicant has provided a designated Play Area for 0-5 year olds, which is 533sqm and a 570sqm Multi Use Games Area (MUGA) in the South west corner of the scheme for teenagers. Although the play area calculated in line with the SPG indicates the need for 1600sqm of play area

page 7 and thus there is a shortfall in play space provision, considering the proximity of the site to the park, amenity space and the provision of the MUGA, the proposal is acceptable.

Urban Design

39 Good design is central to all objectives of the London Plan 2011 and is specifically promoted by the policies contained within Chapter seven which address both general design principles and specific design issues. London Plan Policy 7.1 sets out a series of overarching design principles for development in London. Other design polices in this chapter and elsewhere in the London Plan include specific design requirements relating to optimising the potential of sites, the quality of new housing provision, tall and large-scale buildings, built heritage, the public realm and the Blue Ribbon Network. New development is also required to have regard to its context, and to make a positive contribution to local character within its neighbourhood (Policy 7.4).

40 In the pre-application meeting the overall design was welcomed, subject to: review of east- west connections, including pedestrian links from Great Fleet via Choats Road and home zone courtyards; tightening of the form of courtyards; strengthening the urban frontage along Renwick Road by using facade treatment (e.g. flank wall balconies edged in brick) and careful treatment of the linear park landscaping; balconies to be min.1.2m; to show details of landscaped areas and play space calculations in application.

41 The broad design rationale expressed in the design and access statement (including the addendums) is supported, and it is acknowledged that the proposals would significantly contribute to improving the nature of the area, improving north-south and east-west connections and creating a network of open spaces are all strongly supported.

Layout

42 The applicant was advised that the building footprints should allow for the continuity of a pedestrian/cycle route from the Choats Road through to Crouch Avenue. A crossing over Renwick Road should also be investigated.

Continuity of Choats Road route

43 The building footprints obstruct the continuity of the route of the Choats Road through to Crouch Avenue. It is noted that it may not be possible to make this a through route for vehicular traffic, due to junction issues with Renwick Road. However the route could have an emphasis on pedestrian and cycle use. A crossing over Renwick Road will be required

44 As the layouts below indicate the applicant has presented a fitting urban design solution in accommodating the suggested layout, in particular as the axis of Choats Road is centred on one of the proposed apartment blocks and on the corresponding pedestrian gateway from Renwick Road. The amended layout align with the courtyards just to the north & south, providing routes east-west to Crouch Avenue and beyond. The design allows pedestrians and cyclists to enter from Renwick Road at points while retaining the physical separation between buildings and Renwick Road. This is welcomed and supported.

page 8

GLA’s suggested vs. the applicant’s amended layouts, respectively

Green Edge to Renwick Road

45 Care has been taken that the green edge to Renwick Road does not become a wide buffer zone, which would reinforce the inward looking nature of the Thamesview Estate, and compromise the idea of an urban edge, particularly south of the raised section of Renwick Road. It is encouraging to see that this is a relatively narrow zone with a single line of trees as commonly found in suburban areas.

46 However, the small grassy hills should be carefully considered so as not to block the visual relationship between traffic on Renwick Road and pedestrians. There are safety benefits in maintaining this visibility both in terms of crime, and traffic accidents where children unexpectedly emerge from between too hills to cross the road.

Residential layout and design

47 The proposals provide a range of houses, flats and duplexes (two storey flats). The eastern section of the site consists of 5, four storey apartment blocks running north to south along the eastern boundary adjacent to Renwick Road. A separate group of three storey houses will occupy the north west corner of the site. No bedrooms will be located on the ground floor due to flood risk. The centre of the site will be developed for three and four bedrooms, three storey houses with private gardens to the rear, located around a series of courtyards for parking and informal play.

Public space courtyards

48 The courtyards appear too wide between the apartment blocks, and too narrow between the terraced houses on Crouch Avenue. These east-west spaces would benefit from being thought of more as streets with a more equal width throughout. The current layout of courtyards is reminiscent of a cul-de-sac format. The space between facing rows of houses could be reduced by reverting to parallel parking on one side, while maintaining perpendicular on the other. The space between apartment blocks could be tightened up by putting more of the play areas together.

page 9

Aerial view looking north west (Source: applicant’s design and access statement)

Defining routes and edges with buildings

49 The layout of terraced houses should reflect the hierarchy of routes by facing on to the more important routes. There are number of occasions where the east-west routes are relatively more important and this should be emphasised by the buildings.

Inclusive design

50 London Plan 2011 Policy 7.2 requires all future development to meet the highest standards of accessibility and inclusion, and requires design and access statements submitted with planning applications to explain how the principles of inclusive design, including the specific needs of disabled people, have been integrated into the proposed development, and how inclusion will be managed and maintained. London Plan 2011 Policy 3.8, expects 10% of all new housing to be wheelchair accessible or easily adaptable for wheelchair users, and 100% of units to meet Lifetime Homes standards. Further guidance to this policy is provided in the Mayor’s Supplementary Planning Guidance ‘Accessible London: achieving an inclusive environment’.

51 The design and access statement (including the addendums) demonstrate that all the proposed residential units are designed to comply with the Lifetime Home Standards and thirty duplex flats (i.e. 11% of the 276 units) can be adapted for wheelchair users and are distributed across each block of flats. This is welcomed and supported, but should be conditioned.

52 The statement confirms that street furniture such as seating, signage, litter bins and lighting posts will all be specified and designed to established principles, in accordance with inclusive design strategies - all street furniture will incorporate elements to ensure that long cane users can locate obstacles and will contrast visually. The access arrangement includes way-finding strategies that utilise landmarks, visual signals, colour and form in addition to traditional signage. These inclusive design principles result in safe, clear connections and circulations throughout the development. This is welcomed and supported, but should be conditioned.

page 10 53 The apartment block parking will be situated in adjoining parking courts and will include 30 dedicated wheelchair parking spaces, which corresponds to the number of adaptable wheelchair dwellings provided. This is welcomed and supported, but should be conditioned. Sustainable development

54 London Plan climate change policies, set out in Chapter 5, collectively require developments to make the fullest contribution to the mitigation of, and adaptation to, climate change, and to minimise carbon dioxide emissions. London Plan Policy 5.2 sets out an energy hierarchy for assessing applications, London Plan Policy 5.3 ensures future developments meet the highest standards of sustainable design and construction, and London Plan policies 5.9-5.15 promote and support the most effective climate change adaptation measures including passive thermal regulation, urban greening, and water management.

55 In the pre-application meeting the applicant was advised to consider a strategy based on the energy hierarchy, with a firm commitment to energy savings at each stage; support proposed connection to District Heating Network and CHP as interim measure; commit to some form of on- site renewable energy; and to aim to meet 44%, not 20% target, subject to viability. Modelling output sheets to be provided by the applicant.

Climate change mitigation

Overview of proposals

56 The applicant has broadly followed the energy hierarchy. However, further revisions and information is required before the proposals can be considered acceptable and the carbon dioxide savings verified. An updated energy strategy should be submitted.

BE LEAN

Energy efficiency standards

57 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 parameter will be improved beyond the minimum backstop values required by building regulations. Other features include energy efficient lighting.

58 The applicant does not seem to have undertaken 2010 Building Regulations modelling. The applicant should commit to energy efficiency measures that can be adopted to enable the development to exceed 2010 Building Regulations compliance through energy efficiency alone.

59 The carbon savings achieved with the use of energy efficiency measures alone should be reported relative to a 2010 building regulations compliant scheme and calculated using 2010 building regulations approved modelling.

BE CLEAN

District heating

60 There are no existing district heating networks within the vicinity of the proposed development. However, the applicant should note that a draft energy strategy for the London Riverside OAPF will be published shortly which will have implications for any heat network in the area.

page 11 61 The applicant should, in the energy statement, demonstrate how and commit to designing an onsite heat network, linking all apartments, in line with the technical standards set out in the "Community Heating Specifications for Barking Town Centre Energy Action Plan".

62 Due to the lower heat density of the houses, the applicant would not be expected to connect these houses to the network.

63 Drawings should be submitted that include:

 space required and location of the energy centre supplying the on-site heat network with heat

 an indicative heat network showing the apartments connected to the site wide heat network

Combined Heat and Power (CHP)

64 The applicant is proposing to install gas fired CHP as the lead heat source for the development. Given the small scale of the proposed development and the complexity involved in managing the use of CHP at that scale, in particular with regards to the electricity sales, further information is required in relation to the strategy for the selling of the electricity.

65 Should CHP finally be adopted as part of the proposals, the applicant should propose a CHP plant size using heat load profiles and to recalculate the carbon savings that would be achieved using 2010 building regulations approved modelling.

Cooling

66 The applicant has anticipated that no mechanical cooling will be required in the residences. However the energy statement has failed to provide the measures that would be adopted to ensure that this is the case and that no overheating would occur in the residential units. These measures should be described and committed to in the energy assessment.

BE GREEN

Renewable energy technologies

67 The applicant has disregarded the use of renewable energy technologies for the proposed development. Out of all of the options explored in the energy statement, the use of photovoltaics (PV) is considered technically viable. The use of PV has however been disregarded on the basics of financial viability. This argument cannot be accepted and the applicant should:

 estimate the roof space that could be used to allocate PV with suitable orientation and inclination and free of significant shading over the year– drawings should be submitted

 calculate the carbon savings that the use of PV could achieve.

SUMMARY

68 The applicant should estimate the regulated carbon emissions of the development in tonnes of CO2 per year after each of the element of the energy hierarchy and after the cumulative effect of energy efficiency measures, CHP (if applicable) and renewable energy has been taken into account.

page 12 69 The carbon savings should be compared to a 2010 Building Regulations compliant development, and be calculated using 2010 building regulations approved modelling.

Climate change adaptation

70 In line with London Plan 2011 Policy 5.3 the applicant should seek to incorporate passive design measures, where appropriate, to minimise the need for active cooling. Proposals should be fully resolved as part of an integrated approach to the design of the scheme, and should be presented in detail within the submitted design and access statement and sustainability statement.

Sustainable drainage & water efficiency

71 The proposed on-site drainage strategy accords with London Plan and PPS25 Guidance. This significantly reduces surface water run off through the use of Sustainable Urban Drainage Strategy, which aims to achieve the London Plan’s Preferred Greenfield Discharge Rate. This includes permeable paving, rainwater harvesting, below ground storage tanks to store flood and rainwater and reduce flows to surface water courses.

72 The sustainability appraisal demonstrates that water efficiency and conservation targets such as water consumption of 105 litre/person/day, will be achieved through specification of water efficient fixtures and fittings for kitchens and bathrooms. Water butts will be supplied in all homes for local irrigation and other fixtures will include: Low flow fittings in all bathrooms and kitchens, dual flush low volume toilets, aerating tap, and flow restrictors to prevent wasted water from taps left running.

73 In terms of green roofing the applicant has stated that the implementation of green roofs has not been considered at this time due to the need to use the roof areas in the evacuation strategy. On balance, this could be acceptable if further investigation confirm that is the case.

Flood risk management

74 The proposal is for residential development, a “more vulnerable” use under PPS25 and within a high flood risk zone (Flood Zone 3a) and requires a Flood Risk Assessment.

75 The submitted FRA (Phase 1) by ARUP confirms that the Sequential Test under PPS 25 has been satisfied and considers the Exceptions Test, as a more vulnerable use (residential) is being proposed on an area of moderate flood risk ( FRZone 3a).

76 The FRA confirmed that:

 It was acceptable to set sleeping accommodation above 4.6m AOD and the design has followed this recommendation.

 Ground floor levels should be set above the water level generated by the 0.1% AEP fluvial event (2.16m AOD) along the Ship and Shovel Sewer.

 The Environment Agency accepted the overall strategy for surface water management and preferred discharge straight into water courses, with petrol interceptors.

 The Environment Agency would like the maximum possible amount of deculverting / opening up of the Ship and Shovel watercourse to improve habitats for water voles.

 The proposals for biodiversity enhancement across the site were welcomed.

page 13 77 In summary, the FRA (phase 1) is acceptable and the final stage (phase 2) of the report should be provided prior to the commencement of development and all the mitigation measures proposed should be conditioned. Employment/training opportunities

78 Continued investment in the skills of London's current workforce will ensure that skills and training provision is tailored to meet current employer demand. The GLA is committed to develop the skills that London needs to sustain economic growth, improving individual's employability skills in order to create a positive impact on the skills levels within all of London's communities.

79 Consequently, and in accordance with London Plan 2011 Policy 4.12 ‘Improving opportunities for all‘, the GLA advises the applicant that an employment and training strategy should be submitted and it should incorporate local employment and training as part of the s106 agreement. Transport for London’s comments

80 TfL is satisfied that as a standalone development, these proposals would be unlikely to negatively impact on the operation of the A13/ Renwick junction, although it is noted that the development will put additional traffic pressure on this junction in the future.

81 250 car parking spaces are being proposed on site, which equates to an average of 0.9 spaces per unit. While this level of provision is within London Plan standards and could therefore be considered acceptable given the site’s low public transport accessibility level, TfL would recommend that applicant demonstrates an approach to car parking supply that is consistent with the Barking Riverside development (0.8 spaces per unit for the final build out), given its close proximity. The scope for reducing the current proposed provision should therefore be considered. In addition, electric vehicle charging points (EVCP’s) will need to be provided in accordance with policy 6.13 of the London Plan. This requires 20% of residential parking spaces to be fitted with EVCP’s, with an additional 20% having passive provision so that they can be easily adapted in the future.

82 The applicant has an aspiration to relocate the existing bus stand/ turning facility, currently located at the end of Bastable Avenue, with the planning statement acknowledging that this will be dependent on the outcome of ‘high level discussions with TfL’. The existing turning head on Bastable Avenue provides an essential part of the bus infrastructure, supporting ELT services, and is not a vacant site. Without this facility, the future safeguarding of bus services in Barking Riverside would be jeopardised, while also reducing reliability on some of the key services to the new developments to the south. Policy 6.2 of the London Plan identifies the importance of safeguarding land for transport and protecting it from redevelopment, and as such, TfL would be resistant to such proposals, as per TfL’s pre-application advice, unless an agreed alternative, to be fully funded by the developer, can be found.

83 The applicant is considering relocating the existing bus turnaround to Barking Riverside. TfL does however have some concerns over this proposed location and questions its feasibility and deliverability. Not only is it unclear whether Barking Riverside Ltd would be willing to accommodate such a facility on their site, who would be paying for its provision is also outstanding, although TfL would expect the full cost of this to be covered by the developer. It is also unclear how Barking Riverside, which is currently gated, would be accessed to allow buses to penetrate the site. Under such a scenario, buses would also incur increased running costs as vehicles would have to travel further to lay over, and this additional cost would subsequently also be expected to be borne by the developer. Based on the information submitted to date, the

page 14 applicant’s proposed relocation of the existing bus turnaround/ layover facility to Barking Riverside does not appear to offer a deliverable solution, and can therefore be considered contrary to policy 6.2 of the London Plan which is unacceptable.

84 Cycle parking provision should be provided in accordance with Policy 6.9 of the London Plan, and be located in a secure, convenient and easily accessible location. The Transport Assessment (TA) statement that there will be ‘generous cycle parking facilities’ remains insufficient and confirmation is therefore required of the exact number of spaces being proposed. In addition, TfL would recommend that in accordance with Policy 6.10, an audit of the key pedestrian routes to/ from bus stops and other local services is undertaken, in order to identify if there are any areas in need of improvement.

85 To limit the impact of the development during the construction period, TfL requests that a construction logistics plan be secured for the site by condition, in accordance with Policy 6.14 of the London Plan. In addition, while details of the waste and servicing strategy are included within the TA, which is supported, TfL would however expect a full delivery and servicing plan secured by condition. A framework travel plan has been included as part of the TA which is supported, and TfL would subsequently expect a full travel plan, which complies with TfL’s travel planning guidance ‘A new way to plan’, to be secured, managed, monitored and enforced through the s106 agreement.

86 In summary, while TfL is satisfied that the proposed development is unlikely to negatively impact on the operation of the strategic highway network, further discussions will however be required in relation to the proposed relocation of the existing bus turnaround facility, as currently contrary to policy 6.2 of the London Plan. In addition, further information in relation to the proposed level of cycle parking, and EVCP’s will need to be submitted, in order demonstrate compliance with policies 6.9 and 6.13 of the London Plan. Local planning authority’s position

87 Barking & Dagenham Council officers have yet to confirm their position. Legal considerations

88 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. 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

89 There are no financial considerations at this stage. Conclusion

90 London Plan policies on principle of land use, housing mix, quality of housing including space standards, affordable housing/rent, tenure split, children’s play space, density, urban design

page 15 & landscaping, inclusive design, sustainable development, flood risk management, employment & training, transport & parking are relevant to this application. The application complies with some of these policies but not with others, for the following reasons:  Principle of land use: the proposed housing development on the site is acceptable.  Housing mix & space standards: the housing mix and space standards comply with the London Plan and should be conditioned.  Affordable housing/rent and tenure split: the financial appraisal should be verified by an independent review.  Children’s play space: Although there is a shortfall, considering the provision of the MUGA and proximity of the site to the parks the play space strategy is acceptable.

 Density: the density is acceptable.

 Urban design & landscaping: applicant should consider the comments made in the report.

 Inclusive design: the access arrangement is acceptable and should be secured through conditions.

 Sustainable development: 2010 Building Regulations modelling, calculation of the carbon savings from the energy efficiency measures and from the PV and roof drawings should be provided.

 Flood risk management: the phase 1 report and the mitigation measures are acceptable, but phase 2 report should be provided prior to the commencement of development and all these should be conditioned.

 Employment & training: employment & training strategy should be provided and secured through s106.

 Transport & parking: further discussion is required in relation to the proposed relocation of the existing bus turnaround facility, and further information should be submitted related to the level of cycle parking and the electric vehicle charging points.

91 On balance, the application does not comply with the London Plan.

92 The following changes might, however, remedy the above-mentioned deficiencies, and could possibly lead to the application becoming compliant with the London Plan:  Affordable housing/rent and tenure split: be committed to an independent review of the financial appraisal.  Urban design & landscaping: respond to the comments in the report.

 Sustainable development: provide 2010 Building Regulations modelling, calculation of the carbon savings from the energy efficiency measures and from the PV and roof drawings.

 Flood risk management: Agree to the conditions of submission of phase 2 report and on the mitigation measures.

page 16  Transport & parking: Agree to further discussion in relation to the proposed relocation of the existing bus turnaround facility, and provide further information related to the level of cycle parking and electric vehicle charging points.

for further information, contact Planning Decisions Unit: Colin Wilson, Senior Manager - Planning Decisions 020 7983 4783 email [email protected] Justin Carr, Strategic Planning Manager (Development Decisions) 020 7983 4895 email [email protected] Tefera Tibebe, Case Officer 020 7983 4312 email [email protected]

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